Disposal Of Drill Cuttings (TAGM - 4032)

Issuing Authority: Michael J. O'Toole, Jr.
Title: Director, Division of Environmental Remediation
Date Issued: November 21, 1989

Purpose
This document presents disposal alternatives for drilling cuttings and spoils from the installation of monitoring wells or soil borings at Class 2 sites. For the purposes of this TAGM, the Site shall be considered one "Area of Contamination" as defined in the RCRA Land Disposal Restrictions.
Introduction
This document specifically addresses the handling of drill cuttings derived from remedial investigations at or near Class 2 sites. The disposal of these cuttings may generally be subject to the derivative rule [Part 371.1 (d)(3) and (4)] which defines any waste derived from a mixture of a listed hazardous waste as a hazardous waste and requires handling of these materials as hazardous wastes. Soil containing listed hazardous wastes must be managed as hazardous wastes unless delisted in accordance with Part 370.3(a) and (c).
Disposal of Cuttings and Spoil Generated On-Site During Remedial Investigations of a Class 2 Site
Drill cuttings and spoils generated on-site during Remedial Investigations of a Class 2 inactive hazardous waste site are presumed to be hazardous wastes. Such cuttings and spoil may be disposed at the Class 2 Site provided the following precautions are taken:
1. The drill cuttings may be disposed within the borehole subject to the following:
  1. The bore will not be used for the installation of a monitoring well (cuttings may be used to backfill boreholes resulting from soil sampling);
  2. The bore did not penetrate an aquitard nor an aquiclude;
  3. Backfilling the borehole with cuttings will not create a significant path for vertical movement of contaminants. Soil additives (bentonite) may be added to the cuttings to reduce permeability;
  4. Six (6) inches of cohesive, compacted soil will be placed over the area of the bore; and
  5. Cuttings not disposed in the borehole will be managed as described below.
2. In general, the cuttings or spoil may be disposed within the confines of the Class 2 site provided all other precautions presented below are taken.
3. Cuttings and spoil from several wells which are chemically compatible (see Item e. below) may be collected and disposed at one on-site location provided all other precautions presented below are taken.
4. The cuttings and spoil may be stored temporarily on-site to allow for dewatering prior to disposal. Water which results from the dewatering may be allowed to infiltrate the site. During storage and upon disposal, cuttings and spoil shall be covered to prevent the release of chemical contaminants into the air or surface waters which might escape the site. Generally, six (6) inches of a compacted, cohesive soil will be a sufficient cover.
5. To ensure that contaminated cuttings may be safely managed on-site, the following precautions shall be taken:
  1. If pure wastes are present in the cuttings, the material shall be sampled and analyzed to ensure chemical compatibility with other cuttings before placing the materials in a common storage/disposal area;
  2. Cuttings which are stored/disposed on-site in bulk (not in containers) shall be monitored for volatile emissions and for fugitive dust emissions. Monitoring instruments available at the site as determined by the site-specific Health and Safety Plan (HASP) may generally be sufficient. If any action level specified in the HASP is exceeded, corrective actions such as interim cover, placement in containers, etc., shall be implemented promptly.
6. Drill cuttings shall be handled and disposed of in a manner that does not pose a threat to health and the environment.
Drill cuttings and spoil generated during Remedial Investigations on a Class 2 inactive hazardous waste site may also be disposed at a properly permitted treatment, storage, or disposal facility. Representative samples of cuttings and spoils will have to be analyzed to determine if the materials are a "hazardous waste" or a "solid waste" and to ensure proper classification, treatment, and disposal.

Cuttings and spoils sent off site for disposal shall be transported by a hauler licensed in accordance with 6 NYCRR Part 364, and if determined to be a hazardous waste, the waste shipment shall be accompanied by a manifest in accordance with 6 NYCRR Part 372. The project manager shall be responsible for implementing sufficient controls over the work, to ensure the wastes are properly disposed. Such controls include issuance and collection of "trip tickets", collection of receipts for tipping fees, etc.
Disposal of Cuttings and Spoil Generated During Remedial Investigations Near or Adjacent to a Class 2 Site
Drill cuttings and spoils generated during Remedial Investigations near or adjacent to a Class 2 Site are not presumed to be hazardous wastes nor solid wastes until such materials are first sampled and analyzed.

Such materials shall be collected and transported to the Site for storage/disposal unless an alternate disposal method is proposed and determined to be acceptable at the project review for the RI/FS work plan. Transport need not be accompanied by a manifest nor must a licensed hauler be used. Such materials may be disposed on the Class 2 Site provided all the precautions detailed in Section III above are satisfied.

Drill cuttings and spoils generated during Remedial Investigations near or adjacent to a Class 2 Site may also be placed in containers and transported to an approved treatment, storage, or disposal facility. In order to determine proper containers, treatment, storage, or disposal, representative samples of the materials shall first be collected and analyzed. If the materials are determined to be hazardous, disposal off site shall be at a properly permitted treatment, storage, or disposal facility. Hazardous wastes shall be accompanied by a manifest and shall be transported by a licensed hauler. All drill cuttings and spoils generated during remedial investigations for which there is no known "Site" shall be placed in containers, sampled, analyzed and transported to a permitted facility for proper treatment, storage or disposal.

If the drill cuttings and spoils are determined to be non-hazardous, off-site disposal is allowed at any permitted solid waste management facility authorized to receive such solid wastes. Such solid wastes shall be transported by a licensed hauler. The project manager shall be responsible for implementing sufficient controls over the work, to ensure the wastes are properly disposed. Such controls include issuance and collection of "trip tickets", collection of receipts for tipping fees, etc.
Implementation
The procedures described in this TAGM shall serve as guidance to all Project Managers as of the date of the TAGM. It shall be the responsibility of the Project Manager to arrange for the disposition of drill cuttings before completing the field work related to a remedial investigation.